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Mr. Dustin Czapla <br /> August 24, 2021 <br /> Page 4 <br /> proposes to use sodium bisulfate and lead nitrate at the Mill,both of which are harmful to humans. <br /> (EPP Table 21-3 and § 21.6.1 at 21-9.) Moreover,when these materials are used in the process or <br /> are spilled, they will be discharged to the Tailings Storage Facility ("TSF"), which is a disposal <br /> pit where the toxic chemicals will be left for eternity, or until they leak from the pit. <br /> Cyanide and other chemicals that are proposed to be used at the Mill, and the waste <br /> products from those uses, are too dangerous to be used and disposed of within only a few hundred <br /> feet of residential property and drinking water wells. Therefore, the Concerned Citizens request <br /> that the Board deny the Application. <br /> Mining Plan <br /> Article 4.0 of the Application contains the Mining Plan. The Mining Plan provides little <br /> understanding of how material will be managed and moved through the Mill and into the disposal <br /> pit. If the Application is not denied, the Concerned Citizens request that the Board require the <br /> Applicant to provide a detailed explanation of the flow of material through the Mill, including <br /> identification of each piece of equipment and the manner of conveyance between each step. <br /> 4.2 Mill Management Activities: The Concerned Citizens provide the following specific <br /> comments regarding the Mill Management Activities: <br /> • Purportedly, process water will go to a sump, but the Application is not clear as to where <br /> that sump is,other than within the Mill. (Mining Plan at 4-9,Table 4-5.) The Mining Plan <br /> indicates that the sump can deliver material to the disposal pit, but the text is ambiguous. <br /> The Applicant should be required to explain and provide engineered drawings of the sump <br /> and the means by which it delivers materials to the disposal pit. In addition,the sump and <br /> related conveyances should be engineered to prevent seepage to the environment. Those <br /> controls should be clearly identified and explained. <br /> • 22.88 tons per hour of process water will be sent to the sump. (Id.) Applicant should <br /> identify the rate of process water delivery to the sump in gallons per minute and provide <br /> an explanation as to how the sump can handle that rate of flow. <br /> • The Mining Plan states that"The reagent mixing area is at the fine ore bin level." Applicant <br /> should be required to describe the containers in which reagents will be mixed and how <br /> those containers will be managed to prevent leaks and spills. <br /> • "Any spillage not cleaned up at the source will be washed down to the sump." (Mining <br /> Plan § 4.2.5 at 4-13.) Applicant should be required to identify the type of surface across <br /> which spillage will be washed down. That surface, and the sump surfaces, should be <br /> required to be sealed to prevent seepage. Applicant should be required to inspect those <br /> sealed surfaces regularly and to repair any cracks or other damage that might compromise <br /> the seal or otherwise allow seepage. In addition, Applicant should identify any vertical <br /> BURNS FIGA & WILL <br />